Government Service Insurance System v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from an ejectment suit filed by the Government Service Insurance System (GSIS) against Leonides Makiramdam. The GSIS sought to have Makiramdam vacate the premises known as Lot No. 26, Block 44(6), and the housing unit constructed thereon, located in Nangka, Marikina, Metro Manila. Additionally, the GSIS requested payment for accumulated rentals from March 1967 and attorney's fees. Procedural History: The Municipal Court of Marikina ruled in favor of the GSIS, ordering Makiramdam to vacate the premises and pay back rentals and attorney's fees. Upon appeal, the Court of First Instance of Rizal reversed this decision. The GSIS then filed a notice of appeal, appeal bond, and record on appeal, which was approved by the Court of First Instance. Subsequently, the respondent Court of Appeals, upon motion by Makiramdam, dismissed the GSIS's appeal, granting the GSIS the right to file a petition for review within 30 days. The Petition: Instead of filing a petition for review with the Court of Appeals, the GSIS filed the instant petition with the Supreme Court. The GSIS contended that the Court of Appeals erred in not resolving on appeal that the decision of the Court of First Instance was not supported by substantial evidence and that its conclusions were contrary to law and jurisprudence. The Supreme Court, however, dismissed the petition, affirming the Court of Appeals' resolution and reiterating the rule that decisions of the Court of First Instance in ejectment suits originating from the Municipal Court are reviewable only by a petition for review, not by ordinary appeal or record on appeal, citing relevant jurisprudence and Batas Pambansa Blg. 129.
Issue(s)
Whether the Court of Appeals erred in dismissing the appeal filed by the petitioner via record on appeal. Whether a decision of the Court of First Instance in an ejectment suit originating from the Municipal Court is reviewable by ordinary appeal or record on appeal.
Ruling
The Supreme Court sustained the challenged resolution of the Court of Appeals, dismissing the petition without prejudice to the filing of an appropriate petition for review before the Intermediate Appellate Court.
Ratio Decidendi
On the issue of the Court of Appeals' dismissal of the appeal: The Court held that the Court of Appeals did not err in dismissing the appeal filed by the petitioner via record on appeal. It is a settled rule that a decision of the Court of First Instance in an ejectment suit originating from the Municipal Court is reviewable only by petition for review, not by ordinary appeal or by record on appeal. This procedural rule is crucial for the efficient administration of justice, particularly in summary ejectment cases where prompt resolution is often paramount. The petitioner's chosen mode of appeal was therefore procedurally infirm. On the reviewability of the Court of First Instance decision: The Court reiterated the established rule that a decision of the Court of First Instance in an ejectment suit that falls within the exclusive original jurisdiction of the municipal or city court is reviewable only by a petition for review. This rule was clearly laid down in Gutierrez v. Magat and reiterated in Buenbrazo v. Marave. The Court emphasized that this procedural requirement has been in effect since the enactment of Rep. Act No. 6031 in 1969. Furthermore, Section 22 of Batas Pambansa Blg. 129 explicitly provides that a review of decisions of the Regional Trial Court in cases falling within the original exclusive jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts shall be made by petition for review to the Intermediate Appellate Court. This legislative intent underscores the specific appellate pathway for such cases.
Main Doctrine
A decision of the Court of First Instance in an ejectment suit originating from the Municipal Court is reviewable only by petition for review, not by ordinary appeal or by record on appeal, pursuant to Section 45 of the Judiciary Law as amended by Rep. Act No. 6031 and Section 22 of Batas Pambansa Blg. 129.